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ABS | CODE OF ETHICS 2018 | i

CODE OF

ETHICS

2018

© Pressmaster/Shutterstock

ABS MISSION

The mission of ABS is to serve the public interest as well as the needs of our members and clients by promoting the security of life and property and preserving the natural environment.

ABS GROUP MISSION

The mission of ABS Group of Companies is to be a leading global provider of technical services that better enable our clients to operate safely, reliably, eficiently, and in compliance with applicable regulations and standards. We are focused on adding value to the industries we serve and strategically capturing synergies with ABS.

TABLE OF CONTENTS

Who Must Follow the Code?........................................................................ .......................1

Our Guiding Principles

.................................2

Using the Code

Reporting and Non-retaliation Policy

....4

Treating One Another Fairly

......................6

Disclosing Conicts of Interest

.................8 Complying with Economic Sanctions, Import and Export Laws and Anti-boycott Laws ..........................11

Avoiding Corrupt Practices

.......................14

Money Laundering

Oering and Accepting Gifts

...................17

Protecting Information and Assets

......20

Ensuring Data Protection and Privacy

.22 Competing Fairly in Accordance with Industry Standards ..................................25

Maintaining Good Financial Controls

...27

Focusing on Safety and Environmental Awareness

Investing in Our Communities

..................31

Ethics and Compliance Resources

........33

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MESSAGE FROM THE CHAIRMAN

One of our most important assets at ABS

and ABS Group is our reputation for ethical and reliable service. It a?ects every aspect of our business and operations. Whether we are providing classi?cation services, assisting clients with asset integrity and reliability, certifying systems or processes, or engaging in any number of other tasks, the industries we serve count on us to provide an independent and impartial view that can be trusted.

We trade on our integrity. Each of us is

personally responsible for maintaining the credibility of this organization. We must, at all times, operate at the highest level of integrity. And we must continue to build on the trust and loyalty we have cultivated over the years with our clients.

Within the

Code of Ethics you will ?nd

the standards and practices that form the foundation for conduct based on integrity.

This is your guide to ful?lling your ethical

and legal responsibilities as an employee of ABS or ABS Group. This document also establishes guidelines for interacting with one another as well as clients, stakeholders and competitors. We expect every member of our team to follow the Code. If you have any questions regarding the information in this document, I encourage you to reach out to your supervisor or contact a member of the Ethics and Compliance team. An open dialogue regarding ethical behavior is a cornerstone of our organization. This includes the freedom for any employee to raise concerns about possible infractions of the

Code, in good faith, without fear of retaliation.

A strong commitment to ethics and integrity is not just good business - it is part of the fabric of who we are as an organization and as individuals - the

Spirit of ABS

. Our clients trust us to be their partner. We trust one another to operate according to the highest standards of conduct. It is our commitment to ethics and integrity that has laid the foundation for past and future success, to the bene?t of us all.

Sincerely,

Christopher J. Wiernicki

Chairman of ABS and ABS Group of Companies

ABS | CODE OF ETHICS 2018 | 1

The short answer is: everyone. The Code of

Ethics

is applicable to all employees of ABS and its aliates, including ABS Group of Companies (the Company). The Code also applies to third parties who work on behalf of the Company, such as agents, independent contractors and other non- employee representatives.

Ocers, supervisors and other management

personnel are responsible for enforcing the

Code within their specic areas of supervisory

responsibility. This responsibility includes a commitment to review the Code with their employees to make sure they understand its provisions, and to encourage open communication about the Code, including raising questions and compliance concerns.

WHO MUST FOLLOW THE CODE?

PENALTIES FOR VIOLATIONS

Employees who fail to comply

with the Code are subject to disciplinary action, up to and including termination of employment.

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2 | CODE OF ETHICS 2018 | ABS

OUR GUIDING PRINCIPLES

Our day-to-day business is guided by three principles: integrity, good faith and excellence.

INTEGRITY

comes from consistently behaving according to a set of values and ethics. We are committed to maintaining the highest level of ethical conduct in all of our actions, wherever we operate throughout the world. This commitment includes complying with all laws and regulations.

GOOD FAITH

is inherent in all of our dealings. Whether working with colleagues, customers, vendors, representatives of government agencies or other parties, we will always demonstrate respect, sincerity, honesty and impartiality. Our pledge to always act in good faith preserves our reputation as a trusted business organization that serves the public good.

EXCELLENCE

and its pursuit are fundamental to the success of our business. Through our company-wide commitment to excellence, we strive to meet our customers" needs while serving the best interests of our surrounding communities and the public at large.

These principles are the foundation of the

Code of Ethics, which helps dene who we are

as a company. By incorporating them into everything we do, our Company will be strong and successful and recognized as a valued business partner.

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USING THE CODE

The success of our Company depends on every individual's commitment to strive for the highest standard of ethical business conduct at all times. The Code serves as a blueprint for doing what is right and for acting ethically and in compliance with the law, no matter where we conduct business. It is not a book of instructions but rather a set of guidelines created to highlight ethical standards and protect our Company's reputation as we conduct business worldwide, across di?erent countries and di?erent cultures. Although the Code cannot address every possible scenario you could encounter, it will support you in making ethical decisions and understanding when and how to seek additional guidance. Where local laws, cultures or customs di?er from the principles and standards established in the Code, you should seek guidance from Ethics and Compliance.

THE CODE PROMOTES

The highest level of honest and ethical conduct

Protection of con?dential and proprietary information Compliance with applicable laws, rules and regulations

Open communication and prompt reporting of

violations

A culture of mutual respect

What would you do?

When faced with a

dificult situation that is not speci?cally covered in the Code, use your good judgment and common sense. Ask yourself the following questions:

Am I uncomfortable

with what I am being asked to do? Does it violate any law or regulation?

Is the action consistent

with Company policies?

Is it consistent with

the Company's guiding principles?

Could it put the

Company's reputation at

risk?

How would I feel if the

situation was reported in a newspaper or on a news website?

Would I want my family

to know about it?

Before acting, would I

feel more comfortable talking through my concerns with my supervisor?

Would I want someone

to treat me in the same way that I would be acting?

If something seems

unethical or improper, it probably is. If you are unsure of what to do, don't guess. Play it safe and ask before acting.

Seek assistance from your

supervisor or Ethics and

Compliance.

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CODE OF ETHICS 2018

| 3

4 | CODE OF ETHICS 2018 | ABS

REPORTING AND

NON-RETALIATION POLICY

Open communication about the Code is fundamental to its integration into our culture and daily activities. We encourage employees to discuss ethics openly with their peers and to seek advice from supervisors and other managers about the right course of action when a questionable situation arises. Supervisors have a duty to provide guidance in ethical business conduct, and their doors should always be open. However, if you do not feel comfortable approaching your supervisor, you can report your concern or discuss your question with Ethics and

Compliance.

REPORTING CONCERNS

Each of us has a duty to report illegal or unethical conduct within our workplace. Reporting concerns and asking questions is fundamental to following our Code. The Company takes all reports of misconduct seriously. Your identity and the information you provide will be shared only to the extent necessary with those responsible for addressing the concern. To report a concern, the best place to start is generally with your supervisor. Remember, it is your supervisor"s job to help solve problems. But if you are not comfortable speaking directly with your supervisor, there are several other options available to you.

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